In order to make the pathway more direct and attainable to qualified CDA’s in Virginia we ask for review to amend regulations to create a pathway for dental assistants with 5-10 years of experience to take the Certified Restorative Functions Dental Assistant (DANB) exam and have the employing dentist observe and approve of their capabilities to become a Certified Dental Assistant II.

I'm in favor of approving this modification. 

If the assistant has the ability, and can pass out of an exam, I don't see the need for a one year training program. 

I believe this modification will keep Virginia more in line with other states with requirements for tiered assistants. 

Thank you for your consideration of this issue. 

Dear Board of Dentistry members,

I am against the Petition for Rule-Making to allow DAIIs to have on the job training.  On the job training is spotty at best.  Just because you have assisted for several years does not negate the fact that formal training is required to perform chairside duties.  The VA BOD has training regulations set forth for DAIIs to obtain certification.  DAIIs in Virginia are allowed to perform more invasive procedures than any other state in the country that allows expanded function.  For this reason, all DAIIs should graduate from a CODA accredited program where educational standards are set and maintained.  While other health professions like physical therapy, occupational therapy, pharmacy and nursing have increased educational requirements for their professions; dentistry consistently requests for less training and education for DAIs and DAIIs.  The public deserves a qualified, college-educated practitioner.  Our profession needs to work with integrity to address very real issues our profession faces without compromising our duty to first, do no harm to patients, coworkers and the public depending on us.

All the best,

Tammy

I believe this would be great for both Dentists and Assistants. From my understanding, Certified Dental Assistants have been through one to two years of school already and I feel if they are able to pass a National Board test the I would be capable and qualified enough to observe and decide if an assistant is up to par. Ultimately, as a dentist, I would be liable for any work an assistant performed wile working under my license.

This would be a great opportunity to dental assistants with 5-10 years experience. If they are able to pass their boards and work under supervision of employing dentist that should be all that is needed for the said person to be a DAII.

I am in favor of this. Well qualified DA II's can improved much needed access to care.

I believe this is the next level for dental assistant. Not only will it save time and money for us but we will get more of a hands on learning with the dentist himself. What i’m trying to say is if we are assisting as a DA I we can see for ourselves how a certain procedure is done and have the dentist explain the steps and why. I can see why some others may disagree with this because they may believe this is just an easy way out from taking a test or class. It may be because of the dentist themselves. But this is just my opinion. Whichever one is chosen I know myself that I will like to be a DA II.

I believe this could be an amazing opportunity for Dental Assistants interested in becoming a DA II although, this could be a risky petition to approve. The competency, skill, and ability of each DA II would greatly depend on the dentist that trained that individual. This brings to thought that in order for this to be beneficial to both the dental assistants and the general public there would need to be a baseline that each assistant would need to meet, as well as guidelines for both the assistant and dentist to follow. Not every dentist works the same or has the same views or preferences and because of this, if one assistant completes all training and meets requirements under one dentist and then that assistant tries to become employed elsewhere; the new dentist may not agree with how that assistant was trained and may not feel comfortable hiring that individual as a DA II at their practice. At this point the assistant would have to make the decision to go through this process all over again or settle being hired as a DA I.

I feel as if the licensed Dentist has authorized and approved a DA I’s capability to become a DA II there should be no problem. Colleges teach basics and if a DA I has the opportunity to do on the job training, seeing and learning in the real world; I say go for it! The licensed Dentist should be the ones imputing more because they will be the ones allowing and training. Its a great opportunity and if the licensed dentist entrusts that person they know they will be liable, so they know who to and who not to entrust with this certification. 

I have been a dental assistant for 9 years. I took a dental assistant class and became a certified dental assistant right out of high school. While the class taught me the book side of things it did not teach my the hands on portion of the job very well. Every doctor is different from the materials they use to the techniques they prefer. I learned more by working than reading a textbook.

I worked as an assistant as I earned my associates degree and completed my prerequisites for dental hygiene. Unfortunately while I have a passion for dentistry hygiene is not for me. I love being an assistant and I want to become a DA II. After looking into it there is no possible way for me to become a DAII without quitting my job. The closest class is 2.5 hours away. I have a family to provide for and can not afford to quit my job to take a DA II course. If a certified dental assistant with significant experience has a doctor sign off on clinical hours and they can pass the exam why not allow them? 

I started this petition because I could see a need. 

I think it is great that Virginia expanded it's functions as there are so many things a dental assistant could proficiently do to help dentists more. I live in a border town (NC) where I packed cord for 10 years only to come to VA and it be prohibited. 

I have noticed a lot of dental assistants in VA are not Certified Dental Assistants. I am however Certified through DANB (Dental Assistant National Board). I also teach dental assisting at our local community college. I teach Dental Materials, Radiology, and Clinical Assisting I and II. Our program is a one year program that only prepares the assistant for the NELDA exam which is the entry level Dental Assistant Exam. Usually it is a two year program that prepares assistants for the CDA portion. Even though we teach only for NELDA the students learn and test on everything a DAII would do also. We place fillings in dexter teeth, pack cord, take all types of impressions among many other things. In addition to the classes our students take they have to work for a dentist for two years before they can take the exam to become a CDA. 

That said, a CDA has two years or equivalent of Dental Assisting School. To become a DAII currently we would need another year of school. A dentist only spends 4 years in dental school. A hygienist only spends 2 years in school. But a CDA is asked for 3 years to be a DAII?  When the hygienist were able to provide local anesthetic they weren't asked to reenter school for another year to do so. 

I do not think this is a step back in education at all. I think this will push more of Virginia's Dental Assistants to seek their CDA Certification so they can later obtain their DAII license. Taking these exams is neither easy nor cheap. For a CDA to pass these exams they would need to study to brush up and update their skills and knowledge to pass them. These tests would cost a CDA I believe at least $500 to take. These are the SAME tests the DAII in the year long program are asked to take. If a CDA can study pass these and have a dentist willing to let them do the work under their license then why shouldn't they be able to?

You can argue that each dentist would have to gauge a newly hired DAII's abilities because of what some people consider office training. I can argue that ALL dentists should be gauging ALL new hires abilities anyway. If it were my dental license,  I would. Any dentist or corporate office who cares would. 

Furthermore, I said with 5 or 10 years experience as I don't feel any student straight out of school and with no experience has learned enough. There is a lot to be said for learning in the field. That is why there are externships and internships in the health fields. Not everything can be taught in a a classroom. 

Thank you for your consideration. I hope this passes, or at least opens talks for new avenues toward improving the obtainability of the DAII licensure. 

I am  in favor of granting this petition  .   As a practicing Dentist of over 4 decades and as a former dental educator I have had the opportunity to evaluate many dental assistants ,   Those who love the practice of dentistry and work to improve their knowledge and skills  for decades are very special people. Often family needs and rural or small town areas limit  formal education in a traditional environment ,   With my experience it is my belief that those dedicated to our profession need and deserve this pathway to certification as dental assistant II , Jesse R Wall DDS

In Virginia, the opportunity for a CDA to advance to the DAII status is very difficult.  The CDA that has the passion and desire to perform expanded duties and has the years of experience in the dental office, has no where to go to get the DAII licensure or the opportunity is very limited.  By allowing direct training and supervision by the dentist, duties can be delegated to the assistant thus increasing their passion for dentistry.  A CDA that is allowed to contribute to the quality care of their patients becomes a vital team member of the practice and develops the confidence to do more.  The more qualified assistants available the less stress the dentist experiences.  Even if a dentist hires a licensed DAII in Virginia, he or she must prove they are qualified to perform the duties delegated them to the satisfaction of the dentist.  Usually training is still required by the dentist even if the DAII is licensed, in order to meet that particular dentist's standard of care.  A CDA that has dedicated years to a career in dentistry, and has a personal desire to do the work should , in my opinion, be given the opportunity.  I have been a CDA for 40 years and have dedicated my life's work to dentistry.  I feel fully qualified to be given the legal opportunity to perform duties I have assisted with for 40 years.  A well qualified assistant is someone that most dentist would like to utilize more, so why not let them take that responsibility to properly train them to their advantage.  I think if young DA's had a dentist to mentor and train them every one would win!

Donna T. Smith, CDA

.

It would be great if this passed and it is long overdue. Last time my assistants and I checked into it, there was not even a program available to produce a DAII.  I have two assistants who have been in dentistry over 20 years who would love to extend their skills. It would be a great help to the office and I have all confidence that they would do an excellent job. If these assistants with experience can pass the needed test I see no reason they could not do the job. 

The value of the expanded function dental assistant  (DAII) has already been acknowledged by the creation of the title several years ago. No one is suggesting that training be diluted - just more accessible for those individuals who aspire to an elevated level of training.  As a past President of the American Dental Assistants Association, I traveled the country testifying before dental boards and  interacting with educational facilities. I observed first hand the diversity and benefits of expanded functions. I am also a member of the Fortis Advisory Committee where the DAII was first taught and is not  currently available  thus further limiting access to this accomplishment. As  part of a national Task Force that studied credentialing for dental assistants over a period of two years, we observed the diversity in training and delegable duties of all states.  In instances where there was some form of preceptorship, there was a strict curriculum and individual competency examinations. It is a doable process; however, specific details must be evaluated.

Dear Honorable Members of the Board of Dentistry,

I write to oppose the petition to create a pathway for dental assistants with 5-10 years of experience to take the Certified Restorative Functions Dental Assistant exam and have the employing dentist observe and approve of their capabilities to be a dental assistant II.

The duties delegated to the DA II in Virginia are those that are a part of the art and science of dentistry.  It would be a disservice to the patients in the Commonwealth to allow the proposed kind of practice.  Those who want to practice as a Dental Assistant II need to be educated in an accredited institution and supervised by unbiased practitioners before being allowed to perform such services on a patient.  Dentists do not have time to pay attention to the detail needed to teach such art and science while trying to run a practice/business.  Nor do all practicing dentists have knowledge of pedagogically or andragogically sound teaching principles.  

As a program director for a Dental Assistant II program, I have looked at the requirements of the Certified Restorative Functions Dental Assistant Exam offered by the Dental Assisting National Board.  This exam does not address the expanded functions of a dental assistant II as defined by the Virginia Board of Dentistry.  We must be quite careful to know the varying definitions and uses of the words "expanded functions."  For example, Tennessee views coronal polishing as an expanded function and one reserved for a certified dental assistant.  This is not the case in Virginia.  

While I fully support the maximum utilization of allied dental professionals, this needs to be done in a way that is going to ensure the highest quality of care for our patients.  The Board of Dentistry has a duty to protect the citizens of the Commonwealth.  Reducing the educational requirements of a DA II would be a dereliction of duty.  

Respectfully submitted,

Misty L. Mesimer, RDH, MSCH, CDA 

As an RDH with DAII training, I am strongly against allowing on the job training. The duties delegated to the DA II in Virginia are those that are a part of the art and science of dentistry. I had completed hygiene school and was practicing dental hygiene for 6 years prior to starting the DAII training and realized that there was still a lot that I needed to learn when it came to the duties of a DA II. It would be a disservice to the patients to allow the proposed kind of practice.  While I support allowing auxiliaries to practice at the maximum potential to increase access to care,  on the job training is not the solution. Those who want to practice as a DA II should be educated in an accredited institution and supervised by unbiased practitioners, giving them a solid foundation before being allowed to perform such services on a patient. Not all practicing dentists have sound teaching principles and are able to devote the time and attention to the detail needed to teach such art and science while trying to manage their practice. 

To My esteemed members of the Virginia Board of Dentistry,

I am writing to you today to humbly ask that the petition for the OJT pathway for dental assistants to become DAIIs in Virginia be denied.  I am in favor of having more dental auxillaries in the work force so that quality care can be more assessible to patients, but we need to make sure the quality of care provided is not jeopardized over quantity.  I have been saying for quite some time now, that the lack of uniform training among dental assistants in Virginia is a problem, but at least with DAIIs, thanks to the regulations that have been in place, requiring CODA accredited schooling, by unbiased professionals with proven teaching skills, the quality of care has been standard.   Patients deserve to know that no matter who they see in the dental office, they are being cared for by the most highly trained individual. A dental assistant who wishes to become expanded functions should also be willing to take the courses necessary to learn not only the how's but the whys and science behind what they are doing.  Doctors just do not have the time, and some do not have the teaching ability, to dive that deep into the science.  When I went though the courses I needed for my license,  the textbooks used were the same textbooks several of my doctors used when they were in dental school.  We studied the science behind the practice, and learned not just that A, B, and C were done, but why it was important to do A, B, and C, and even the techniques behind it.  The science taught in the formal school setting, from the head and neck anatomy to tooth histology, to the biochemistry behind how the bonding of resin composite to teeth works, just can't be taught OJT, but is necessary for the dental assistant to be competent in what he or she does.  In the nursing field, licensure is necessary from CNA to LPN to RN to BSN and higher.  They take standardized, uniform classes and exams.  As patients we can be cared for by those professionals with confidence that a certain level of education was earned.  As Dental professionals, we are healthcare providers too. 

Thank you for your time,

Michelle Fisher, CDA, CPFDA, CRFDA, RDAII

I'm a mechanic that got wind of the proposal for dental assistants to beable to be trained on the job to place fillings and what not.  I'm against this.  Just as you wouldn't want someone who was taught on the job to be working on your car, over an ASE trained and licensed mechanic, I want to know that the person fixing my teeth has has as much training as possible.  It's hard to find a dentist that you can trust anyway, but then to wonder if my filling is going to come out or if my crown is going to fail because I wasn't sure if the person doing the work was properly trained, no thank you.  We both work in fields, me automotive mechanics and you dentistry, where the trust of the public has been decreased.  I think as the board of dentistry, you'd want to do everything you could to build confidence of the people, and you do that by making sure those you license are properly educated and trained using uniform standards, which you can only regulate through some sort of accredited teaching program.

Yours truly,

Frank Fisher

I think we should be striving to improve the quality of education and training our dental professionals, well all healthcare providers, obtain in order to work on a patient.  If lack of opportunities is the problem, then add the opportunities, don't lower the bar for everyone.  That's not far to those who have gone through the schooling, and it certainly isn't fair to the patients who trust that the dental professional placing their fillings is highly trained.  We make dentists, people who have been practicing for years, from other countries go through our dental schools.  We do this so we know that they are fully trained because the training isn't uniform overseas.  Why view the dental assistants, especially the expanded functions ones, any different?  If they are placing fillings or cementing crowns--work that licensed dentists (who have not only earned a four year undergraduate degree but also spend four plus years in dental school) do--shouldn't there be some standard, uniform training from accredited sources for those assistants too?  I think so.  

As a patient, I want to know that the person working in my mouth has had a certain level of training.  I can usually tell when an assistant has been formally educated or not.  I've been to dentists where the dentist did everything and the assistant basically handed him things. And I've been to dentists where not only did the assistant do most of the work, she was so knowledgeable, and explained things to me so completely, that honestly, I thought she was at least a dental student intern if not the doctor, until the doctor came in the room and I saw that my assumptions were incorrect.  The assistants that can explain things to me, tell me what they are doing step by step and why, they make me more comfortable in the chair, that I am otherwise a little nervous to sit in.  If I have to worry whether the assistant who is placing my filling was trained in an accredited school or was taught on the whim by a doctor, maybe not even a doctor I know or trust, then that is going to hurt my confidence and trust in the profession, a profession that sometimes gets a bad name anyway.  

I am writing to oppose the petition to create a pathway for dental assistants with 5-10 years of experience to take the Certified Restorative Functions Dental Assistant exam and have the employing dentist observe and approve of their capabilities to be a Dental Assistant II.

Having worked as a dental office manager, dental assistant and dental hygienist in Virginia for over 30 years, I can attest that the necessary skills and science needed for the duties delegated to the DA II in Virginia can not be gained through on the job training. A practicing dentist does not have the time or resources available to provide quality dental care for patients, while also providing on the job training to staff members.

To pass this petition would be a disservice to both the patients and the prospective DA II, who deserves an education from an accredited program. Reducing the educational requirements would be moving the profession in the wrong direction.

Respectfully Submitted,

Pam Blankenship 

I am opposed to this proposition for on the job training for DAIIs in Virginia.  My mom is a DAII in Virginia, and she rocks.  I've watched her go through all the classes and helped her study.  She put in hours of studying and the stuff she had to learn, I don't see a doctor having the time to teach all of that in the dental office.  If the dentists have to go through school and learn the theory behind what they do, then a dental assistant that is doing what the dentist does, should also know the theory.  On the flip side, as a patient, I feel like the profession should move in the direction of having more education and formal training, not less.  Patients deserve no less.  Going forward with this proposition would be a disservice to the profession, current DAIIs, prospective DAIIs and the patients.

I am opposed to amending the existing law. I believe that DA II applicants need the education and the practice involved with the schooling aspect, and the benefits of the extra education vs taking an exam, are immense. 

i have been a DA II for 4 years, an assistant for a total of 9 years and personally, I would not have been adequately prepared or knowledgeable enough to place fillings as well as I can now, without the school, the clinical s, the studying, the dentists and school staff reviewing my work closely. 

Remembering the patients that I first started placing my first fillings on, they were nervous as it was, after 1.5 years of school, so if i were to go back and have no school, I can only imagine the feelings of those patients. Public perception is important 

i think also the petition will dissuade more dentists from allowing DAII to practice in their offices. It is slim the number of offices that have da II anyway right now. 

we need to keep the education requirements there. A simple exam and OJT years under our belt is not enough. 

I am writing in opposition to the petition for "on-job training" for dental assistants to become a DAII.  I have 14 years of experience as a dental assistant of which the last three years were as a DAII.  I have seen both on the job trained dental assistants and formally trained dental assistants and I can tell the difference in the quality of work between the two.  Those who have formal training do a much better job.  In my experience, the patients also notice the difference in terms of the quality of service provided, with those that have had formal training giving higher quality work as compared to those that have not.   I see this petition as a step back in terms of the safety of the patients and the quality of care; especially, when compared to the requirements in other states. I believe the loosening of the qualification requirements would be a detriment to the profession and the patients and would open the state up to legal liability when on the job trained DAII’s malpractice on patients.  Please do not deny the importance of formal education and maintaining high qualifications for the profession.  Dentists have years of formal education in addition to on the job training and standardized examinations in order to be allowed to provide dental care for patients.  If it is not acceptable for people to become dentists through on the job training and formal examination alone without the formal education, then it should also not be allowed for DAII’s.  We as dental auxiliaries should have our profession protected and the same logic applied in requiring formal, accredited education as with dentists in order to ensure the integrity of the profession and protect the patients from harm.  Patients deserve qualified knowledgeable dental care providers whether they be dentists or DAII’s.  Formal training as a DAII at school is an essential part of ensuring the integrity of the profession and to protect the patients from harm.  At school an instructor is dedicated to teaching and supervising their trainees without the pressure of working in their private practice where the doctor’s primary focus is on running their business and not training staff to perform complicated procedures on their own.  If anything, the solution to the shortage of DAII’s to encourage more educational institutions in the state to become accredited to training DAII’s.  The requirements to work as a dental assistant in Virginia are already less stringent than other states compromising the quality of care and safety of the patients.  Therefore, I ask that the requirements to become a DAII are not lessened, as it would prove detrimental to the patients health and allow for legal liability, but instead continue to allow those assistants that have taken the time and effort to be properly trained to give patients the excellent standard of care that is to be expected of a DAII. Thank you for your consideration of my comments and perspective.

I am writing against the petition to allow dental assistants to practice as DAIIs without any formal training. As a patient I would not feel safe having an assistant perfom any procedure on me that was not properly trained by an accredited university. Having someone who might have been trained in a rush or not given the proper training do anything makes me uneasy as in the end it is me that would suffer from their lack of proper care. I would definitely prefer having someone that knows what they are doing and who have been trained at a school be the ones who work on my teeth. As such I am against dental assistants becoming DAIIs without having the proper training as I feel that it would lower my standard of care.

Dear Board Members,

I strongly disagree with this petition.  I feel that this petition will be detrimental to the field of dental assisting, dentistry and the rights of patients to be in competent hands.  This would discredit the art and science of dentistry and the education that it requires to effectively perform the procedures.  It takes dentists years of education at a School of Dentistry to learn the science and art of proper restorations. It takes dental assistants that strive for higher education, years of training and additional education to be competent to effectively do the same tasks that are licensed to dentists.  I recently completed Oral Anatomy and Operative Dentistry through a CODA certified DA II program at Germanna Community College. This was a pre-requisite to be able to even apply and be accepted for my lab and clinical skills to attain my DA II in Virginia.  I have been an OTJ trained dental assistant for 20 years, a CDA of my own decision for 12 years, and was an EFDA in Kentucky, through U of K School of Dentistry.  Virginia did not allow me to reciprocate my EFDA skills to this state due to the program that I had completed not being CODA certified. I felt this unfair until I recently completed the Oral Anatomy and Operative Dentistry course.   Now, I realize the education that I was missing from my previous training.  Virginia was right to require my training to be through a CODA certified program.  Even with my 20 years in the field and additional training I did not have the education needed to effectively be restoring teeth.   I don’t feel as if any dentist could appropriate the time to give an assistant the proper training in their office to be a DA II, while they are trying to treat patients and run a practice.  This is not to discredit the abilities of any dentist, as I have worked for and currently work with two exceptional dentists.  The office setting is just not the place for thorough DA II training. To allow this petition through will be taking a step that will be allowing severely under trained assistants to be treating patients.  From experience, I can say that patients will notice this.   We have a Virginia licensed EFDA in our office and patients inquire daily about her education and training.  They are only appeased and comforted by the discussion that she has been trained in an educational institution and licensed by the Commonwealth of Virginia to be providing their care.  Patients will lose their faith and trust in their dental providers if this petition goes through and becomes a new law.  As an elected Board, you have a duty and responsibility to be an advocate for the people and protect their rights and health, and assure that they get the best possible dental care. 

Summer Woodard, CDA and Team Leader at Powell Valley Dental in Big Stone Gap, VA

I am writing against the petition to allow dental assistants without formal training to become DAII's. Being a dental assistant working in the field for more than 13 years as well as a formally trained DAII for the last 3, I have seen both people with skills and people with knowledge. From experience I know that having an assistant with skills is very useful but having someone with the knowledge that comes from formal training really makes the difference, not only for the doctor and the team but most importantly for the patient. Providing the best care and service for the patient's health and wellbeing means not only having a certain number of years on the field, but having the training, practice and nuanced knowledge of the anatomy of the mouth as well as the different dental materials necessary for each procedure that only comes through formal learning; that is what quality standard of care is all about. This is a professional health field and it must be kept that way in order to provide the best of our knowledge and skills to the patients. Although I was forced to drive an hour each way to get my accreditation, I am absolutely sure that it was the right decision and I know that it provided me with the right training to excel in my field. Most doctors will not have the time to supply their staff with the proper knowledge and training in order to make them fully functional DAIIs,and that makes it unfair for a patient to be subjected to a lower standard of care. Therefore, I feel that approving the petition to allow dental assistants without formal training to become DAIIs would be detrimental to the profession, subjecting patients to a lower standard of care that comes with not giving the assistants the proper training that can only come from formal learning. We must keep the standard of care to its highest potential, and this can only be reached by ensuring that those who have the drive to become DAIIs do it through the proper pathways. Thank you for taking the time to consider my petition.

There are multiple reasons this petition should not be considered, the top two for me are training and liability.

As adjunct faculty at a CODA accredited dental assisting program the training and clinical aspects of expanded function education is of upmost importance.  Educators are well trained, faculty/staff undergo a calibration of sorts to produce graduates who can all pass the same extensive testing and board examinations.  This is true of all dental schools, hygiene programs and assisting programs who are accredited.  When you think back on your education, remember all of the different clinical faculty and the vast differences between them and expectations they each placed on you as a student.  Also remember the multiple patients and learned techniques used to become the efficient practitioners you are now.  Once graduating you each found your own preferred way to practice.  Each doctor has their own way of completing treatment.  Once completing a program where they learn the basic skills, assistants are on the job trained by whom they work for the specifics of that doctor’s four handed technique.  This is standard because the assistant is doing just that, assisting.  Restorative general dentistry takes years to become proficient in even with the benefit of faculty/staff who can truly take the time to “teach” skills.  I cannot imagine there are many practicing dentists who have the time, calibrated education training or willing patient base to accomplish proficiency for expanded function criteria.  To have an assistant be on the job trained for expanded function assisting is simply not a beneficial way to achieve the required quality clinical skills set by CODA accredited programs.

On to liability.  Once an assistant has completed an accredited program for expanded function and has passed the clinical exam as well a written exam he/she is responsible for his/her own liability and treatment outcomes.  If on the job trained, who will ultimately be liable for subpar treatment?  This alone should deter this moving forward.  I fear the assistant could deflect liability based on training if there is not a clear standard set forth such as in a CODA accredited program. 

As a former assistant who would have met the years criteria in the petition I can promise, based on the multiple practitioners with whom I have worked, there is no way this type of on the job training would come close to meeting the necessary training for an assistant to be as proficient as required by the state of Virginia and it’s licensing board.

Thank you for your consideration of my opposing this petition,

Marlene Rhodes CDA, BSDH, RDH

Adjunct Faculty J Sargeant Reynolds Community College

VDHA 02 Component Chair, VHyPAC Director, Legislative Chair

Dear Honorable Members of the Board of Dentistry,

I write to you on behalf of Virginia Health Catalyst (Catalyst) staff, board, and partners. Catalyst is a statewide advocacy nonprofit committed to ensuring all Virginians have equitable access to affordable, comprehensive health care that includes oral health.

Thank you for the opportunity to provide comment on the Virginia Board of Dentistry’s public petition for rulemaking to amend requirements for Dental Assistant IIs (DAIIs). Catalyst does not support the petition as written.

Catalyst staff and partners are committed to promoting programs and initiatives to increase the number of DAIIs in the commonwealth; we understand the immense value they bring to oral health care teams by supporting dentists and expanding patient capacity. Standardized training and certification is vital to develop both a robust network of DAIIs and an appropriate workforce pipeline in the commonwealth.

Catalyst is currently convening a taskforce (Future of Public Oral Health) comprised of oral health stakeholders from across the commonwealth to develop recommendations to improve public oral health systems and care in the wake of COVID and the inequities it amplified. While the recommendations are not final, the taskforce members recognize the tremendous value DAIIs bring to oral health teams and are considering opportunities to increase access to education and certification to ensure more DAIIs are practicing in the commonwealth. This will include a practical and standardized DAII pipeline of education-to-certification-to-employment. We welcome new partners to join us in this important work.

If you have any questions, please do not hesitate to contact me at sholland@vahealthcatalyst.org.

Thank you,

Sarah Holland

Chief Executive Officer, Virginia Health Catalyst

Dear Distinguished Members of the Virginia Board of Dentistry:

I am writing on behalf of the Dental Assisting National Board, Inc. (DANB) in connection with the petition for rulemaking to amend requirements for a Dental Assistant II that is currently the subject of a public comment period ending December 31, 2020.

As you may know, DANB is the ADA-recognized national certification board for dental assistants and administers the nationally recognized Certified Dental Assistant™ (CDA^®) certification program and four other certification programs for oral healthcare workers, including the Certified Restorative Functions Dental Assistant (CRFDA^®) certification. DANB’s CDA certification is required for registration as a Dental Assistant II in Virginia. DANB’s mission is to promote the public good by providing credentialing services to the dental community; as part of that mission, DANB collects and compiles information about dental assisting laws and regulations across the country and serves as a resource to stakeholders seeking information about dental assisting practice in any of the states.

About DANB Certification Eligibility Requirements

The petitioner has asked the Virginia Board of Dentistry “to amend regulations to create a pathway for dental assistants with 5-10 years of experience to take the Certified Restorative Functions Dental Assistant exam and have the employing dentist observe and approve of their capabilities to be a dental assistant II.”

The wording of the petition seems to indicate that the petitioner believes the Virginia Board of Dentistry has the authority to alter or amend the DANB CRFDA certification eligibility requirements. Although we know the Board is aware it does not have such authority, for the benefit of all stakeholders participating in this discussion, we would like to explain that CRFDA certification is a private certification program developed and administered by DANB, and only DANB’s Board of Directors may make changes to certification eligibility requirements. Individual states may recognize or require one or more component exams that make up CRFDA certification to earn a state-specific license, registration or certificate, or states may require that an applicant for a state credential earn CRFDA certification, but states do not determine the content of the exams or the certification eligibility requirements.

Having said that, however, we would also like the Board and stakeholders to be aware that DANB does consider input from stakeholders about certification eligibility requirements when those requirements are periodically reviewed, and that any feedback about DANB certification may be submitted via email to Dr. Johnna Gueorguieva, DANB’s Chief Credentialing and Research Officer, at jgueorguieva@danb.org.

About CRFDA Certification

If the Board is interested in establishing a pathway to the Virginia Dental Assistant II credential that includes successful performance on the CRFDA certification exam as one of the requirements, allow me to provide the following summary of CRFDA certification eligibility pathways:

Pathway I

1.   Current or former DANB CDA certificant whose certification lapsed for no more than two years.

2.   Current hands-on CPR, BLS or ACLS from a DANB-accepted provider.

Pathway II

1.    Graduation from a Commission on Dental Accreditation (CODA)-accredited dental assisting or hygiene program, or Registered Dental Hygienist (RDH) status (from any state except Alabama).

2.    Current hands-on CPR, BLS or ACLS from a DANB-accepted provider

Pathway III

1.    Completion of an Expanded Functions Dental Auxiliary (EFDA) or restorative course/program offered by an institution with a CODA-accredited dental assisting, dental hygiene or dental program. Each function does not have to be listed separately, but the documentation must indicate that expanded functions/duties or restorative functions/duties were included in the course curriculum.

2.    Minimum of 3,500 hours work experience as a dental assistant, accrued during the previous two to four years; employment must be verified by a licensed dentist.

3.    Current hands-on CPR, BLS or ACLS from a DANB-accepted provider

I have also sent a copy of this letter to the Board via email. That email message includes an attachment (Attachment 1) containing exam outlines for each of the four component exams that make up the CRFDA certification.

As the Board considers the petitioner’s proposal, we direct your attention to Pathway I above, which is the only pathway that would allow an individual who has not completed formal education to qualify for CRFDA certification. Candidates for DANB’s CDA certification must either graduate from a CODA-accredited dental assisting program or complete 3,500 hours of work experience over a two- to four-year period to meet CDA eligibility requirements. (There is also a third CDA eligibility pathway for dentists trained outside the U.S. or Canada who wish to earn the CDA certification.) The only way an individual who has not completed formal education could qualify for CRFDA certification would be to first earn the CDA certification through the work-experience pathway, and then qualify for CRFDA through Pathway I above.

Restorative Functions Requirements in Other States

The scope of practice for Virginia Dental Assistants II includes functions that are considered expanded functions in those states where they may be performed by some level of dental assistant. Although the scopes of practice for Expanded Functions Dental Assistants (EFDAs) and equivalent levels of dental assistant roles vary from state to state, performance of restorative functions – that is, placing and finishing amalgam and composite restorations – is the cornerstone and common denominator of EFDA practice.

For your reference, we have provided, via email, a chart (Attachment 2) that shows the states where some level of dental assistant may perform placement and finishing of direct restorations, the level of dental assistant permitted to perform the function, and the requirements to attain that level in each state. We hope these data will aid you in your consideration of the current rule petition.

DANB thanks the Board for the opportunity to comment on this petition for rulemaking. If there are any questions about the foregoing or any of the attachments, please don’t hesitate to contact me at klandsberg@danb.org.

Dear Members of Board of Dentistry,

It is a great opportunity to have different pathways for a certified dental assistant who is motivated to expand the knowledge and skills to move in their career forward in dentistry to provide standard of care necessary for dental patients.

I am an assistant professor of an accredited dental assisting program, while I fully support expanding duties of trained dental assistants with the knowledge skills of science and art of dentistry, I have reservation with the pathway provided as it is.

I am in support of provision for more pathways to obtain title dental assistant II (DAII), which include proficiency of all state allowable duties as a DAII. However, the pathway that was suggested may not suffice, as it is. It is beneficial to have other options of education such as DANB certifications to include all skilled dental professionals and also it is important to establish a board approved standard performance clinical examination to test clinical skill competencies, which is conducted by an approved educational institute approved by state regulatory board to maintain highest standards of our profession.

Respectfully,

Piumini Wanigasundera BDS, MEd, CDA

Opposed to amendment 

Opposed - 

A lot of jobs will be lost and proper didactic training is gone. Therefore, I opposed to this petition.

David Minoza Jr. DDS, CDA

DNA Program Director

Reynolds Community College | School of Health Professions

DMinoza@reynolds.edu

804-523-5380

reynolds.edu

Downtown | Goochland | Parham Road | Reynolds Online

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